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Treasury and IRS Issue Initial Guidance on Stock Buyback Tax and Corporate Minimum Tax

New guidance clarifies certain key points on implementing the 1% tax that generally applies to public company stock buybacks and the 15% corporate minimum tax that generally applies to corporations with book income exceeding...more

Analysis: Impact of Inflation Reduction Act’s Stock Buyback Excise Tax and Corporate Minimum Tax

Beginning in 2023, an excise tax of 1% will apply to public company stock buybacks and a 15% corporate minimum tax generally will apply to corporations with book income exceeding $1 billion. Key Points: ..Public...more

G7 Tax Agreement Marks Significant Step Toward Global Tax Reform

The agreement builds on the two-pillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy. Key Points: ..Under Pillar One, the largest and most...more

Tax Considerations for Financing and Refinancing Transactions in Turbulent Times

Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences. Key Points: ..Issuers may incur immediate income in the...more

DAC 6 Deadline Nears: What Does the Mandatory Disclosure Regime Mean for Taxpayers and Advisers?

The 31 December deadline for EU Member States to adopt implementing legislation for DAC 6 is fast approaching. Intermediaries and taxpayers must be ready for compliance. By the end of 2019, each Member State of the...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

Congress Passes Tax Reform Legislation, Implementation Imminent

Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications. Key Points: ..The bill adopts, with some modifications, earlier US House and Senate tax reform...more

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

Potential legislation would significantly affect businesses across a variety of sectors. Key Points: ..US House and Senate have each passed comprehensive tax reform legislation. ..Proposals would alter fundamental...more

Tax Reform Update: Administration and Congressional Officials Unveil Framework

The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details. On September 27, a group of Trump Administration and Congressional leaders...more

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

Tax Reform Update: 4 Issues to Watch as Congress Nears Summer Recess

Administration and Congressional tax negotiators abandon border adjustment tax, but leave unanswered questions regarding rates, revenues, and taxation of US multinationals. As Congress heads toward its late summer 2017...more

US Tax Court Exempts Gain on Sale of a Partnership Interest

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups. Key Points: ..Tax reform...more

IRS Tightens Rules on Disguised Sales and Allocating Partnership Liabilities

New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions. On October 4, 2016, the Internal Revenue Service (IRS)...more

Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments

Seeking to curb “excessive” use of related-party debt, Treasury and IRS retain basic framework, but significantly narrow the scope, of the Proposed Regulations. On October 13, 2016, the US Department of the Treasury...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

New Long-Term Extension of Wind and Solar Tax Credits Subject to Phase-out

Congress extends tax credits for wind and solar energy projects, but will phase the credits out over several years. The Consolidated Appropriations Act, 2016 (the Act), which President Obama signed into law on December...more

New Tax Audit Regime Constitutes a Sea Change for Partnerships

Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect. The Bipartisan Budget Act of 2015 (the Act), which President Obama...more

11/9/2015  /  Audits , IRS , K-1 , Partnerships , TEFRA

IRS Rulings Clarify Tax Treatment of Multi-Tier Restructuring Transactions

By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques. A pair of revenue rulings the US Internal Revenue Service (IRS)...more

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